Nyrstar Group Policy: Anti-Corruption. Revision 1. Review Date September Page 1 of 6

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1 Nyrstar Group Policy: Anti-Corruption Document No. (English) Revision 1 Review Date September 2013 Page 1 of 6

2 Contents 1 CONTEXT 3 2 SCOPE 3 3 REFERENCES AND RELATED DOCUMENTS 3 4 DEFINITIONS 3 5 BRIBERY AND FACILITATION PAYMENTS 4 6 GIFTS, ENTERTAINMENT AND TRAVEL 4 7 BUSINESS PARTNERS, AGENTS, CONTRACTORS AND OTHER THIRD PARTIES 5 8 DONATIONS AND SPONSORSHIPS 5 9 AUDIT AND REVIEW 6 10 ACCOUNTABILITIES 6 11 REPORTING 6 12 RELEVANT CONTACTS 6 Page 2 of 6

3 1 CONTEXT Nyrstar s reputation is built upon being open and honest one of the elements of the Nyrstar Way. This means acting with honesty and integrity in our management practices and business transactions. It is therefore vital for Nyrstar to prevent corruption in all its forms. This Policy was developed to assist Nyrstar in this. As a policy can however not cover every eventuality, good judgment and common sense needs to be applied at all times. 2 SCOPE This Policy applies to: all Nyrstar employees; non-employees performing services for or at Nyrstar (e.g., consultants, independent contractors, suppliers, temporary workers, etc.); and any other third parties acting directly or indirectly on Nyrstar s behalf. Compliance is mandatory and a condition of employment, assignment or doing business with Nyrstar. For ease of reference, the above mentioned categories will in this Policy collectively be referred to as Nyrstar employees. 3 REFERENCES AND RELATED DOCUMENTS Nyrstar Group documents: The Nyrstar Code of Business Conduct Nyrstar Group Contracting Procedure Nyrstar Group Policy: External Partnerships, Sponsorships & Donations 4 DEFINITIONS The following section outlines definitions that relate to this Policy. Bribery means the giving or receiving of money, a gift or other advantage as an inducement to do something that is dishonest, illegal or a breach of trust in the course of doing business, in order to gain any commercial, contractual, regulatory or personal advantage. Corruption means a dishonest or fraudulent conduct by those in power. The most common form of corruption is bribery. Corrupt acts can involve Government Officials or private parties. Facilitation payments are unofficial payments (usually involving a small amount) to a Government Official (often at a lower level) to secure or expedite a routine action or service to which an individual or company is entitled. Gift means anything of value given or received where the recipient does not pay fair market value. Government official means: Page 3 of 6

4 an officer or employee of a government (holding an administrative, judicial or legislative mandate) or of a department, agency or instrumentality thereof or any person acting in an official capacity for or on behalf of such government (e.g. an entity hired to review bids on behalf of a government agency or to collect custom duties); an officer or employee of a public international organisation or any person acting in an official capacity for or on behalf of such public international organisation (public international organisations include, for example, the United Nations, the World Bank, the European Commission, etc.); an employee of a company or other business entity in which a governmental body has an ownership interest and/or over which such governmental body may, directly or indirectly, exercise a dominant influence (such employee can qualify as a government official even if he or she is engaged in commercial, rather than governmental, activities); and a political party or a member of a political party or a candidate for political office. Additional caution should be applied in respect of persons who are known or suspected to be family members of Government Officials or in respect of companies who are controlled by family members of Government Officials so as to avoid that these persons serve as a conduit for an illegal payment to a Government Official. 5 BRIBERY AND FACILITATION PAYMENTS Bribery is prohibited. Nyrstar employees must not commit, or be a party to, or be involved in bribery. Nyrstar employees cannot, directly or indirectly, offer, promise, give, demand or accept any bribe or other undue advantage in order to obtain, retain or direct business or secure any other improper advantage in the conduct of business. This applies whether dealing with Government Officials or with private individuals or enterprises. Facilitation payments. In many parts of the world facilitations payments are prohibited. Nyrstar complies with national and local laws and regulations. Therefore, any facilitation payment, directly or indirectly, to Government Officials must be pre-approved by the Compliance Officer. Payments to protect your safety are permitted. When Nyrstar employees face payment demands that involve explicit or implicit threats to personal safety they may make payments which would otherwise be prohibited. In such circumstances, Nyrstar Finance Manager must ensure that such payments are recorded in the Nyrstar books of accounts accurately as payments made to preserve personal safety and reported as quickly as reasonably practicable to the relevant Nyrstar general manager and Compliance Officer. 6 GIFTS, ENTERTAINMENT AND TRAVEL Never give or receive cash. Nyrstar employees must not give or receive money or cash equivalents (such as gift cards, certificates or vouchers) as gifts. In a very few situations it is customary to make cash payments (e.g. funerals in Japan). This course must be pre-approved by the relevant Nyrstar Finance Manager and General Manager. Gifts, entertainment or travel can be bribes. Therefore, gifts, entertainment and travel must not be provided or received, directly or indirectly, with the intention or effect of improperly obtaining, retaining or directing business or securing any improper advantage. Any gift, entertainment and travel must be permitted by local laws and policies of third parties. In addition, gifts, entertainment and travel that Nyrstar employees promise, offer or give to, or accept or receive from, third parties must: Page 4 of 6

5 be customary, in type and value, in the relevant country and be given or received at an appropriate time or season (e.g. in some countries it is customary for small gifts to be given at Christmas time ) and/or in appropriate circumstances; be given or received in the name of Nyrstar and not in personal name of the employee or third party. Entertainment events must have the Nyrstar host (who is giving the entertainment) present. As a general guideline: gifts such as promotional items of little value (e.g. inexpensive pens, mugs, T-shirts, calendars etc., that bear the company s name and/or logo); business entertainment in the form of non-lavish meals, beverages or invitations to arts or sporting events (given and received); and travel in the normal course of promoting, demonstrating or explaining Nyrstar s business are acceptable as long as it is in line with local laws and reasonably infrequent. 7 BUSINESS PARTNERS, AGENTS, CONTRACTORS AND OTHER THIRD PARTIES Nyrstar seeks to establish and retain relationships with business partners (whether they are agents, consultants, suppliers, intermediaries, consortium or joint venture partners, contractors or major subcontractors, distributors, to be acquired or merged companies, etc.) who share similar ethical principles. Under anti-corruption laws, Nyrstar could be held responsible for the conduct of its business partners. Therefore : Nyrstar employees must undertake due diligence on its business partners with a view to assessing the corruption risk before engaging in business with them; and Nyrstar s business partners are required to act consistently with this Policy. Nyrstar operates a global multi-metals business and is therefore subject to national and local laws and regulations in various jurisdictions. Nyrstar does not deal with countries and/or corporations or individuals that are subject to international trade sanctions that prohibit international trade with Nyrstar. If you are in doubt with regard to Nyrstar s ability to contract, please contact the Compliance Officer. 8 DONATIONS AND SPONSORSHIPS Donations and sponsorships can be bribes. Therefore, donations and sponsorships must not be provided, directly or indirectly, with the intention or effect of improperly obtaining, retaining or directing business or securing any improper advantage. In addition, donations and sponsorships must be made according to the rules and guidelines as set out in the Nyrstar Group Standard : External Partnerships, Sponsorships and Donations. Nyrstar does not make payments or gifts in kind to political parties, individual politicians or political candidates. Following approval by relevant Finance Manager and General Manager, Nyrstar employees are however allowed to attend specific fund-raising events organised by individual politicians to the extent such events relate to and are beneficial to Nyrstar s business. Page 5 of 6

6 Nyrstar employees may engage in politics but only in their own capacity. Such participation must not involve Nyrstar funds, assets, resources, time or personnel. 9 AUDIT AND REVIEW Nyrstar is committed to conducting audits to ensure compliance with this Policy. Any changes to this Policy will be initiated by the Compliance Officer after consultation and approval by the Nyrstar Management Committee. 10 ACCOUNTABILITIES All Nyrstar site managers are accountable for ensuring the effective implementation and communication of this Policy in their area of responsibility. The Group Manager Business Risk together with Compliance Officer shall be responsible for ensuring that audit and review of requirements for this Policy are implemented. 11 REPORTING Reporting is key to compliance. The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of everyone at Nyrstar. Non-reporting can lead to personal liability. It is important that you immediately report any requests for bribes and any known or suspected payments of bribes, or any suspicious behaviour regarding Nyrstar employees or actions of Nyrstar third parties to your supervisor or manager. If you have done this and still have concerns, or if you feel uncomfortable discussing it with your supervisor or manager, then you may contact the Compliance Officer at in accordance with the procedure as set out in the Nyrstar Code of Business Conduct. 12 RELEVANT CONTACTS Any question regarding this Policy can be sent to: Compliance Officer Virginie Lietaer D: E: Page 6 of 6

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